Sawgrass Asset Management LLC

ITEM 5

    Investment Products

    Matching a client’s investment parameters with an investment strategy designed to meet their
    goals and objectives, risk tolerances and time frames is the focus of our Products. For our Equity
    products our philosophy is to emphasize growth stocks with a consistent and stable earnings
Form ADV: Part 2A                                                                    Sawgrass Asset Management, LLC

                                                                                       DISCLOSURE BROCHURE
    pattern, accelerating earnings estimates and companies with greater earnings potential than the
    market and their peer group. For our fixed income products, our philosophy incorporates an
    emphasis on issuers with strong measures of creditworthiness within a well- diversified portfolio
    Duration and sector allocation are actively managed within defined ranges of that of the
    appropriate benchmark. Managed account(s) may include a combination of the following
    Investment Products.

        Sawgrass Large Cap Quality Growth
        INVESTMENT OBJECTIVE – We combine quantitative models with qualitative research into a
        consistent and structured investment discipline. We believe that in combination, these
        elements allow us to identify companies early in their cycle of positive earnings and estimate
        changes, which can offer our clients above average stock appreciation potential.

           MANAGEMENT FEE

                               Style:   Large company stocks of high quality companies with strong
                                        earnings potential
                    Product Minimum:    $3,000,000
                        Annual Fees:                                                                Annual Fee
                                        Account Value
                                                                                                       Rate
                                        First $10,000,000 .......................................      0.70%
                                        Next $20,000,000 .......................................       0.60%
                                        Over $30,000,000 .......................................       0.50%
                        Key Benefits:   Growth returns with risk control

        Focused Growth Equity
        INVESTMENT OBJECTIVE – We seek to add value over time by uniquely combining proprietary
        quantitative models with qualitative research in a consistent and structured investment
        discipline. Our process identifies companies with high quality balance sheets, consistent
        earnings streams, rising earnings estimates, and reasonable valuations relative to the Russell
        1000 Growth Index. The firm believes that in combination, these four elements allow us to
        identify companies early in their cycle of positive change, capitalizing on above average
        appreciation potential. This strategy tends to use fewer more concentrated positions than does
        our Sawgrass Large Cap Quality Growth product described above.
           MANAGEMENT FEE

                               Style:   Large company stocks of high quality companies with strong
                                        earnings potential
                    Product Minimum:    $3,000,000
                        Annual Fees:                                                                Annual Fee
                                        Account Value
                                                                                                       Rate
                                        First $10,000,000 .......................................      0.70%
                                        Next $20,000,000 .......................................       0.60%
                                        Over $30,000,000 .......................................       0.50%
                        Key Benefits:   Growth returns with risk control

Form ADV: Part 2A                                                                            Sawgrass Asset Management, LLC

                                                                                    DISCLOSURE BROCHURE

       Small Cap Growth Equity
       INVESTMENT OBJECTIVE – The small cap portfolio process identifies domestic stocks with
       greater earnings potential than the market. We believe it is possible to add value over time by
       combining quantitative models with qualitative research in a consistent and structured
       investment discipline. Our process identifies small companies with strong earnings momentum,
       rising earnings estimates, and reasonable valuation relative to the Russell 2000 Growth Index.

           MANAGEMENT FEE

                                Style:   Small company stocks (30-50) with strong earnings potential
                    Product Minimum:     $100,000
                         Annual Fees:                                                        Annual Fee
                                         Account Value
                                                                                                Rate
                                          First $25,000,000                                      0.80%

                                          Next $25,000,000                                       0.70%

                                         Over   $50,000,000                                      0.60%

                         Key Benefits:   Growth potential with controlled risk

       Sawgrass Small Cap Quality Growth
       INVESTMENT OBJECTIVE – Seeks to add value over time using quantitative and qualitative
       research which is applied in a consistent and structured investment discipline. Our process
...

TYPES OF CLIENTS

    We primarily offer our advisory services to institutional clients including, but not limited to, state
    or municipal government pension plans, religious entities pension plans, corporations, charitable
    organizations, foundations, insurance companies, investment advisors, and other institutional
    clients. Although not our focus, we also offer advisory services to high-net worth and other
    individuals. Our minimum account size for portfolio management is disclosed above under
    “Investment Products” in Item 5 above in the “Fees & Compensation” section of this Brochure,
    and we reserve the right to waive any stated minimums at our discretion.

    3    To participate in a performance-based fee arrangement, the client must meet the minimum requirements of SEC Rule 205-3(d)(1), which are only available to
        the client, and even then, only if: (i) The Client fully understand the risks involved in performance-based fee management; (ii) The Client has at least $1,100,000
        under management with us or a net worth equal to or greater than $2,200,000; or, (iii) The Client is a “qualified purchaser” under Section 2(a)(51)(A) of the
        Investment Company Act of 1940.